DOEP Annual Review

does everyone have the BSA Exemption annual review form signed by the Phase II customer? if as a bank you can, due to a separate account maintained, say for lottery sales; prove the ineligible activities do not exceed 50% - not have the form signed.

What does the signature buy you?

Hi JennKK2-
We do not have a signature line for the customer on our BSA Exemption Annual Review Form.

No signature. And we look up their stats in Verafin as evidence that there is minimal revenue due to lottery sales.

hmmmmm
during a FDIC exam it was noted i was not using the appropriate form as the "Customer Signature line" was omitted. it was then pointed out to have the customer sign attesting to the % facts. I had never had this pointed out before, nor had i ever obtained a customer signature. We at the time only had one phase II who had a separate account for lottery so it was easy to prove. I can't find that it is required to obtain one. We now have another phase II who deposits lottery and other sales combined so a bit more challenging. we don't utilize Verafin
Given this recommendation was from the FDIC i asked the board to comment on obtaining a signature or not.

with that said if i DONT HAVE TO HAVE A SIGNATURE then we most likely won't

" i was not using the appropriate form as the "Customer Signature line" was omitted."

What form, there is no "form"? The FDIC might want to review the FinCEN information on what constitutes revenue from the sales of lottery tickets - it is only the merchant's cut, which is usually like $.05 a ticket. They either have to have a pretty poor operation or sell a gob of lottery tickets to not qualify.

$.05 per ticket- I did not realize that.

Thanks.

It might be as simple as altering the form and removing the Customer Signature line.
We do not have our customers sign the form.

Yes we do, and if you have an old form you might want to check that it has been updated to include Cannabis in the ineligible activity list.

Goldrose - where did you obtain a new form regarding the cannabis line?

We have the customer sign the form to attest the eligible and ineligible percentages. We've not had any regulatory issues or customer signature issues. We've added a step that our Compliance Officer has to review all of the supporting DOEP information before formally exempting a customer.